FAME has responded to the draft National Planning Policy Framework by welcoming its objective of delivering sustainable development, ed but expressing concerns about its degree of protection for undesignated assets, medicine its lack of clarity about the development management process, and its lack of emphasis on the need for specialist expertise.
Draft National Planning Policy Framework (NPPF)
I am writing to you on behalf of the Federation of Archaeological Managers and Employers (FAME), which represents around 50 businesses providing archaeological services to commercial clients in the development industry throughout the UK.
We welcome the NPPF objective of delivering sustainable development, and acknowledge its intention to simplify and streamline the planning process whilst preserving the highly-effective policies and principles set out in Planning Policy Statement 5: Planning for the Historic Environment.
We welcome its recognition (Paras 177 and 191) of the importance of recording information revealed by development in advancing knowledge and understanding of the past, and of making the results of such work publicly accessible.
However we do have some concerns about the NPPF as currently drafted.
Firstly, we feel it places undue emphasis (Paras 183-4) on those designated heritage assets which enjoy statutory protection under existing consent regimes, at the expense of the 95% of heritage assets which are undesignated and depend upon a robust and proportionate planning process for their safeguarding and management. In our view it is these non-statutory undesignated assets that most require strong and unequivocal guidance on assessing their significance and setting and in securing their management through the neighbourhood planning process. The ‘balanced judgement’ advocated in Para 185 represents in our view a weakening of the protection afforded to undesignated heritage assets, as a material consideration in determining applications, currently afforded by PPS5 Policy HE8.1.
Secondly, it does not in our view set out as clearly as did PPS5 (or indeed PPG16 before it) the process by which planning decisions affecting undesignated heritage assets are reached. The well-established and effective sequence of pre-application consultation and appraisal, pre-determination assessment and evaluation and post-determination investigation and recording, so clearly set out in previous guidance, is not as clearly signposted in the draft framework. In our view it is vital for our clients that they fully understand the decision-making process, in order both to identify any likely risks to development at the earliest possible stage and to manage them through design solutions or mitigation measures.
Thirdly, whilst making passing reference (176, 178) to the value of the historic environment, we feel that the draft framework significantly understates its potential contribution to place-shaping, regeneration and, indeed, to sustainable growth.
Fourthly, whilst we welcome its recognition of the need for local planning authorities to have access to accurate and up-to-date historic environment records (37), such a requirement is of little value without the necessary specialist expertise to implement it. The NPPF should make specific reference to the need for access to such specialist advice in neighbourhood planning and development management, similar to that provided by PPS5 Policy HE7.1 (vi). It should also include a clear statement of the need for development-led archaeological investigation to be carried out by suitably-qualified archaeological organisations to nationally-agreed standards.
Finally, the NPPF will need to be underpinned by clear and detailed guidance, so that planners, practitioners and local communities can interpret the policies set out in it, and practical methodologies may be agreed for its effective day-to-day implementation.
Adrian Tindall MA FSA MIfA
Chief Executive, Federation of Archaeological Managers and Employers